Jason Lee Miles v. State of Mississippi, 249 So. 3d 362

Jason Lee Miles was indicted for grand larceny (items: four-wheeler, lawn mower, trailer) taken from Donald Coleman; trial began July 11, 2017.
Lavell Coleman (Donald’s brother and attorney‑in‑fact) discovered the theft, identified items in police photos/video, and testified about purchase history and present value estimates.
Police stopped a truck on Jan 5, 2016; video/photographs showed Miles driving with the trailer and lawn mower; lawn mower was returned and identified, trailer and four‑wheeler not recovered.
Miles’s counsel moved for a continuance on the first day of trial, claiming late receipt of discovery and witness lists; the trial court denied the continuance and allowed subpoenas instanter.
Jury convicted Miles of grand larceny (aggregate value ≥ $1,000 but < $5,000); sentence five years (one suspended). Miles appealed, raising (1) alleged incompetence/insufficiency of market‑value evidence and (2) denial of continuance.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Miles)	Held
Admissibility/sufficiency of lay valuation evidence	Lavell, as attorney‑in‑fact and longtime caretaker, had personal knowledge to give lay opinions on value	Lavell was not the owner and thus incompetent to testify to market value; purchase price and opinion insufficient	Court: Lay opinion admissible under M.R.E. 701; Lavell’s testimony about purchase and present value supported jury verdict (affirmed)
Denial of continuance	Trial court properly exercised discretion; subpoenas were issued and defense not shown to suffer manifest injustice	Continuance requested for additional preparation; counsel lacked timely notice and discovery	Court: Issue procedurally barred (not raised in new‑trial motion); on merits, denial not an abuse of discretion and no manifest injustice (affirmed)

Wells v. State, 233 So.3d 279 (Miss. 2017) (standard of review for evidence rulings)
Evans v. State, 25 So.3d 1054 (Miss. 2010) (abuse‑of‑discretion review)
Mouton v. State, 227 So.3d 1079 (Miss. 2017) (continuance review standard)
Totten v. State, 166 So.3d 32 (Miss. 2015) (purchase price as circumstantial evidence of market value)
Gunn v. State, 56 So.3d 568 (Miss. 2011) (using purchase price to infer value)
Morgan v. State, 741 So.2d 246 (Miss. 1999) (preservation requirement for continuance issue)
Pool v. State, 483 So.2d 331 (Miss. 1986) (preservation principles)
Lambert v. State, 654 So.2d 17 (Miss. 1995) (trial judge discretion on continuances)
Hatcher v. Fleeman, 617 So.2d 634 (Miss. 1993) (denial of continuance reversible only for manifest injustice)
Williams v. State, 763 So.2d 186 (Miss. Ct. App. 2000) (lay familiarity does not automatically qualify witness to opine on market value)